member's taxable income, except to the extent that expenses, losses, and other deductions are allocated and apportioned as if all domestic members of an affiliated group were a single corporation under section 864(e) and the regulations thereunder. See §1.861-9T through §1.861-11T for rules regarding

–675) of title VI of Pub. L. 99–514, enacting this part and amending sections 582, 593, 856, 1272, 6049, and 7701 of this title] shall take effect on January 1, 1987. "(b) Rules for Accruing Original Issue Discount.—The amendment made by section 672

(a) Section 955 as in effect before the enactment of the Tax Reduction Act of 1975—(1) In general. In general, §§1.955-1 through 1.955-6 are applicable with respect to withdrawals of previously excluded subpart F income from qualified investment in less developed countries for taxable years

section 424(a) applies. (b) Incentive stock optionFor purposes of this part, the term "incentive stock option" means an option granted to an individual for any reason connected with his employment by a corporation, if granted by the employer corporation or its parent or subsidiary corporation, to purchase stock of any of such corporations, but only if—

connected with such trade or business. (2) Minimum tax on nonresident alien individuals (A) In generalIn the case of any nonresident alien individual, the taxable excess for purposes of section 55(b)(1) shall not be less than the lesser of— (i) the individual's

partnership trade or business, as the case may be. (3) Coordination with subsection (b)A corporation which is treated as a domestic corporation under subsection (b) shall not be treated as a surrogate foreign corporation for purposes of paragraph (2)(A). (b) Inverted corporations treated as domestic corporationsNotwithstanding

. A certificate of sale of personal property given or a deed to real property executed pursuant to 26 U.S.C. 6338 discharges the property from all liens, encumbrances, and titles over which the lien of the United States, with respect to which the levy was made, has priority. For example, a mortgage on real property executed after a notice of a Federal tax lien has been filed is extinguished when the

substituted for "voting stock". (4) Present holdings (A) (i) In applying this section with respect to the holdings of any private foundation in a business enterprise, if such foundation and all disqualified persons together have holdings in such enterprise in excess of 20 percent of the voting stock on May 26, 1969, the percentage of such holdings shall be substituted for "20 percent

This section lists the table of contents for §§1.181-1 through 1.181-6. §1.181-1   Deduction for qualified film and television production costs. (a

(a) Interest and penalties with respect to failure to pay imputed underpayment on the date prescribed. In the case of any failure to pay an imputed underpayment on the date prescribed for such payment (as described in §301.6232-1(b)), a partnership is liable for— (1) Interest as determined

the Secretary, make a return setting forth the aggregate amount of such payments, and the name and address of the person to whom paid. (b) Dividend defined (1) General ruleFor purposes of this section, the term "dividend" means— (A) any distribution by a corporation which is a dividend (as defined in

reasonably broad audience of persons interested in the subject (for example, how and to whom do you intend to disseminate the information). If we have categorized you as a representative of the news media under §2105.36, we will presume you have this ability and intent. (3) How disclosure is likely to significantly contribute to the understanding of a reasonably broad

(a) Basis for computation. (1) The beneficiary's income and tax paid for any prior taxable year for which a recomputation is involved under either the exact method or the short-cut method shall be determined by reference to the information required to be furnished by him under §1.668(b)-4A

(a) Increases and decreases in reservesFor purposes of subsections (a) and (b) of section 807, the sum of the items described in section 807(c) taken into account as of the close of the taxable year with respect to any variable contract

incurred, the owner must make the election for the taxable year in which paragraph (b)(1) of this section is first satisfied, and any production costs paid or incurred prior to the taxable year in which the owner makes the election and not deducted in a prior taxable year are treated as production costs (except costs described in §1.181-2(a)(2)) that are deductible under §1.181-1(a)(1)(i) for the taxable

(a) Required information and materials. A private, national accreditation organization applying for approval must furnish to CMS all of the following information and materials (when reapplying for approval, the organization need furnish only the particular information and materials requested by CMS): (1) The types of Part D plans and sponsors that it reviews as part of its accreditation process

the provision of health care services. Notwithstanding any other provision of law, with respect to obstetrics and gynecological care for beneficiaries not enrolled in a managed care plan offered pursuant to any contract or agreement under this chapter, a nonavailability-of-health-care statement shall be required for receipt of health care services related to outpatient prenatal, outpatient or inpatient delivery, and outpatient post-partum care subsequent to the visit which confirms the pregnancy

(a) General ruleIn the case of an enterprise zone business, for purposes of section 179— (1) the limitation under section 179(b)(1) shall be increased by the lesser of—

June 10, 1890, ch. 407, §20, 26 Stat. 140), relative to the withdrawal of merchandise; section 2971, authorizing withdrawal for exportation, or transshipment to the Pacific Coast, and providing for exclusion of periods when exportation or transshipment should be prevented in computing the three years;